PART OF
In Cooperation with

Privacy Notice

CLIENT ONBOARDING AND VERIFICATION

 

If you provide us with personal information other than your own (for example, identifying other natural person as manager, beneficiary, representative, etc.), please inform them of this Privacy Notice and its contents.

 

FOR WHAT PURPOSE AND LEGAL BASIS, WE PROCESS PERSONAL DATA?

Aviator are part of Avia Solutions Group[1] the largest aerospace business holding in Central & Eastern Europe offering aviation services worldwide. We take a zero-tolerance approach to money laundering and terrorism financing and are committed to the highest level of openness, integrity, and accountability. Seeking legitimacy and being reliable Avia Solutions Group and its subsidiaries conduct business only with reputable clients, suppliers, and partners whose funds derived from legitimate sources and who have no imposed sanctions on them.

Personal Data for Client Verification and Onboarding procedure is processed in accordance with Article 6 Part 1. c) of the GDPR, i. e. our legal obligation to monitor and implement the international and/or national sanctions.

Personal Data for Client Verification and Onboarding procedure is also processed in accordance with Article 6 Part 1. f) of the GDPR, i. e. our legitimate interest to fulfill the requirements for money laundering and financing terrorism prevention, prevention of corruption, bribery, and fraud to be legitimate, reliable, and reputable business to our clients, suppliers, partners, and authorities.

 

WHAT PERSONAL DATA WE PROCESS?

When the client/supplier/partner is a natural person:

Name, surname,  date and country of birth, employment status, occupation, gender, valid ID/passport number, data on whether the client is a politically exposed person, country of permanent residence, residential and registered address details, phone number, e-mail address, bank information (account number), relationship with the third party (if payment will be made by the third party), source of funds/wealth (if payment will be made in cash), signature.   

When the client/supplier/partner is a legal entity:

  • The authorized person to fil the Application Form: name, surname, role/position/title.
  • Ultimate beneficial owner: name, surname, address, profession, date and country of birth, data on whether the person is a politically exposed person.
  • Shareholder: name, surname, address, date and country of birth, data on whether the person is a politically exposed person.
  • Controlling person (e.g., a Chief Executive Officer, Chief Financial Officer, Managing Member): name, surname, address, date and country of birth, data on whether the person is a politically exposed person, role/position of the person.
  • Member of the board of directors: name, surname, data on whether the person is a politically exposed person.
  • Authorised representative: name, surname, address, date of birth, email, phone, role/position.

We also process personal data collected within provided copies of the following documents:

  • Identity Card or Passport.
  • Official documents of public authorities verifying the identity and the place of residence.
  • Documentation proving the source of fund/wealth.
  • Articles of Association authorizing the representative of a legal entity.
  • Certificate of Incorporation or its equivalent.
  • Certificate of Directors or copy of CEO (or other principal management body) appointment document.

 

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data via:

 

HOW LONG WE WILL RETAIN YOUR PERSONAL DATA?

We will process your personal data collected during Client Verification and Onboarding procedure not longer than 5 years unless longer storage of personal data and related documents will be required by applicable laws, legal regulation or institutional/state authorities or will be necessary for the defense in the judicial process. We ensure and take all necessary measures to avoid storing outdated or unnecessary personal data about you.

 

TO WHOM WE DISCLOSE YOUR PERSONAL DATA?

As the Client Verification and Onboarding procedure is implemented groupwide we share your personal data described in this Privacy Notice with Avia Solutions Group companies (listed at https://aviasg.com/en/the-group/general-contacts) if any of the companies is intending to start a legally binding relation with you or your represented legal entity.

We also may share some of your personal data with:

  • Companies acting on our behalf as IT/electronic security service processors.
  • Our professional advisors, auditors, lawyers and/or financial, accounting advisers.
  • Law enforcement authorities at their request or on our own initiative if there is a suspicion that a criminal offense has been committed, as well as courts and other dispute resolution bodies.
  • Banks or other financial service providers who are subject to money laundering, sanctions and prevention of financing terrorism, corruption, bribery, and fraud.

 

To learn more about how we process personal data, and your privacy rights please refer to our Privacy Policy.

If you have any questions regarding the Client Verification and Onboarding procedure, please contact bim@aviator.eu.


[1] AVIA SOLUTIONS GROUP PLC, a private limited liability company, established and acting under the laws of the Republic of Cyrpus, registration code HE 380586, registration addres 28 Oktovriou, 1, ENGOMI BUSINESS CENTER BLC E, Flat / Office 111 Egkomi, 2414, Nicosia, Cyprus.